Whistle Blowing Policy

Whistle blowing policy

The Group is committed to achieving the highest possible standards of service and the highest possible ethical standards in all of its practices. To achieve these ends it encourages employees to use internal mechanisms for reporting any malpractice or illegal acts or omissions by its employees or ex-employees.

This provides an outline of the procedure to be followed when reporting any malpractice, illegal acts or omissions by current or former employees. The policy also covers the protection afforded to employees who do report such activities.

Whistleblower Protection Act 2010 sets out the framework to promote the responsible and protected disclosure of concerns on the following matters:

a) That a criminal offence has been committed, is being committed or is likely to be committed;

b) That a person has failed, is failing or is likely to fail to comply with a legal obligations which they are subject to;

c) Suspected fraud;

d) That the health and safety of an individual has been, is being or is likely to be endangered;

e) That the environment has been, is being or is likely to be damaged;

f) A breach of code of conduct;

g) Showing undue favour over a contractual matter; and

h) Information on any of the above has been, is being or is likely to be concealed.

The Group has implemented a whistle-blowing policy, the objectives of which are as follows:

a) To promote accountability and transparency within the Group;

b) To provide an established channel for legitimate concerns to be raised and where necessary, to take appropriate action(s) to resolve such issues promptly and effectively;

c) To protect an employee from any form of harassment, reprisal or retaliation as a direct consequence of him/ her reporting any wrongdoings under this policy. The protection accorded is to encourage an employee to report such wrong doings whilst removing any fear or risks and to safeguard an employee his/ her identity; and

d) To address a disclosure in an appropriate and timely manner internally within the Group.

Any stakeholder can address his/ her concerns pertaining to matters of the Group to the following persons:-

The procedure allows individuals to have their concerns treated in confidence. In raising a concern employee may assume that only those employees involved in investigating the concern will know the reporting employees identity.

All concerns must be raised in good faith. Anyone who abuses the procedure (for example maliciously raising a concern they know is untrue) will be subject to disciplinary action, as will anyone who victimizes a colleague by raising a concern through this procedure.

The Board is committed to the policy. If anyone raises a concern, he/ she will not be at risk of damaging his/ her position as a result provided they have acted in good faith.

The Group will not tolerate the victimization of anyone raising a genuine concern and anybody responsible will be subject to disciplinary action.

The employee should advise a designated officer of their concerns either face to face or in writing. He/ she should make it clear that the issue is raised under the Group whistleblowing procedure.

The designated officer will arrange an initial interview to assess the areas of concern. At this stage the whistleblower will be asked if he/ she wish his/ her identity to be disclosed and will be reassured about protection from possible reprisals. He/ she will be asked whether or not he/ she wish to make a written or verbal statement. In either case the designated officer will write a brief summary of the interview which will be agreed by both parties.

The employee may be accompanied at the interview by a fellow employee of his/ her choice.

The designated officer will report to the Executive Director who will be responsible for the commission of any further investigation. The Executive Director will brief the designated officer as to the outcome of the investigation who will in turn arrange for a meeting with the whistleblower to give feedback on any actions taken.